https://www.taxtmi.com/caselaws?id=306137 Transfer pricing adjustment on technical know-how fees for bundled intra-group technical and advisory services cannot rest on assigning nil value based on perceived non-use or inadequate benefit. Where the taxpayer has a contractual right to receive services, TNMM cannot be replaced without a proper basis for an alternative method; the adjustment was deleted. Disallowance of expenditure relating to exempt income was confined to the exempt dividend income earned. Depreciation on acquired intangible assets required fresh examination of their nature, valuation and prior transaction treatment. Merger-expense deductibility also required reconsideration because relevant facts had not been adequately examined. en-us Thu, 05 Dec 2019 00:00:00 +0530 Thu, 12 Jan 2023 21:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306137 Transfer pricing adjustment on technical know-how fees for bundled intra-group technical and advisory services cannot rest on assigning nil value based on perceived non-use or inadequate benefit. Where the taxpayer has a contractual right to receive services, TNMM cannot be replaced without a proper basis for an alternative method; the adjustment was deleted. Disallowance of expenditure relating to exempt income was confined to the exempt dividend income earned. Depreciation on acquired intangible assets required fresh examination of their nature, valuation and prior transaction treatment. Merger-expense deductibility also required reconsideration because relevant facts had not been adequately examined. Case-Laws Income Tax Thu, 05 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306137